On January 10, 2008, Cleveland sued Plaintiffs’ parent, Wells Fargo & Company,together with twenty other defendants, alleging, in a public nuisance action under Ohio law, that“subprime lending abuses” have inflicted “damage” upon Cleveland. See Cleveland v. DeutscheBank Trust Company, et al., Case No. 1:08-cv-00139-DCN, ¶ 4. Among other things,Cleveland’s complaint in that case (“the Complaint” or “Cleveland’s Complaint”) alleges (¶ 32)that “[b]etween 2002 and 2006, [Wells Fargo] issued more than 30 billion in securities backed by sub-prime mortgages”; that “Wells Fargo itself also has originated tens of thousands of sub-prime mortgages”; and that “[o]ver the last four years, Wells Fargo has filed more than 4,000foreclosure actions in Cuyahoga County.” Cleveland’s Complaint seeks equitable relief and damages for “a foreclosure crisis as the inescapable consequence of” the defendants’, including Wells Fargo & Company’s, alleged conduct.23.Wells Fargo & Company does not originate, purchase, service, sell or securitize residential mortgage loans. However, Plaintiffs Wells Fargo Bank and WFASC do, and basedon the allegations in Cleveland’s Complaint, Plaintiffs face an imminent threat that Clevelandwill apply the state-law public nuisance theory in its Complaint to their real-estate mortgage loan origination, purchasing, servicing, sales and securitization activities. Cleveland’s nuisance action thereby threatens to impair and interfere with Plaintiffs’ federally authorized powers to originate real-estate mortgage loans and determine the interest rates for such mortgage loans, aswell as to purchase, service, sell and securitize such mortgage loans. Plaintiffs bring this suit to prevent Cleveland’s imminent threat to Plaintiffs’ federal rights.24.In Ohio, “a ‘public nuisance’ is ‘an unreasonable interference with a right common to the general public.’ 4 Restatement, Section 821B(1). ‘Unreasonable interference’includes those acts that significantly interfere with public health, safety, peace, comfort, o rconvenience, conduct that is contrary to a statute, ordinance, or regulation, or conduct that is of acontinuing nature or one which has produced a permanent or long-lasting effect upon the publicright, an effect of which the actor is aware or should be aware.” City of Cincinnati v. Beretta U.S.A. Corp., 768 N.E.2d 1136, 1142 (Ohio 2002).25.Because Cleveland’s action has purportedly been brought to enforce state law,and seeks to vindicate an alleged right common to the general public, its action constitutes“visitation” on Plaintiffs. 12 C.F.R. § 7.4000(a)(2). As such, Cleveland’s nuisance actionthreatens to interfere with the OCC’s exclusive visitorial authority over the Plaintiffs’ banking-related activities.